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HomeMy WebLinkAbout06-0832 CLEVELAND BROTHERS EQUWMENT CO., INC., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO. Ol,.~. 31 C~ --r;~ PAUL D. THRUSH, d/b/a B & D EXCAVATING CIVIL ACTION Defendant CONFESSION OF JUDGMENT CONFESSION OF JUDGMENT Pursuant to the authority contained in the warrant of attorney, the original or a copy of which is attached to the complaint filed in this action, I appear for the Defendant and confess judgment in favor of the Plaintiff, Cleveland Brothers Equipment Co., Inc., and against the Defendant as follows: TOTAL $357,218.51 $64,299.24 $421,517.75 Principal and Interest Collection Fees of l8% plus continuing interest on the unpaid balance of the instrument in the amount of $117.44 per day from January 28, 2006, and costs of suit. t.- W-- Br' n . Downey (PA 59891) Jus n G. Weber (PA 89266) PEPPER HAMILTON LLP 200 One Keystone Plaza North Front and Market Streets Post Office Box 1 l81 Harrisburg, PA 17108-1181 (717) 255- 1 155 Dated: February 10, 2006 Attorneys for Plaintiff Cleveland Brothers Equipment Co" Inc. CLEVELANDBROTHERSEQUWMENT CO., INC., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO. 0[.- Y31- ~ I~ PAUL D. THRUSH, d/b/a B &DEXCAVATING CIVIL ACTION Defendant CONFESSION OF JUDGMENT NOTICE OF ENTRY OF JUDGMENT TO: Paul D. Thrush d/b/a B & D Excavating 972 West Old York Road Carlisle, PA ]7013 Pursuant to the requirements of Pa. R.C.P. No. 236, you are hereby notified that on ...M-.. . A "1 ) 0 , 2006, judgment by confession was entered against you in the sum of $421,517 .75, plus continuing interest on the unpaid balance under the instrument at the rate of 1 2% per annum ($ 1 17.44 per day from January 28, 2006) and costs of suit. Date: LtJ"'''l 10, :J.(jt.J(. Is! C,^1/~ Prbthonotary J?I:~. _ C).1 LL. );~,~. , CLEVELAND BROTHERS EQUIPMENT CO., INC., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO. v(" - S32 ~ I.u...- PAUL D. THRUSH, d/b/a B & D EXCAVATING CIVIL ACTION Defendant CONFESSION OF JUDGMENT COMPLAINT IN CONFESSION OF JUDGMENT NOW COMES Plaintiff, Cleveland Brothers Equipment Co., Inc. ("Plaintiff'), by its undersigned attorneys, and files this complaint for judgment by confession for money. Parties I. Plaintiff is a Delaware business corporation with an office located at 5300 Paxton Street, Harrisburg, Dauphin County, Pennsylvania 17111. 2. Defendant Paul D. Thrush d/b/a B & D Excavating ("Defendant"), is an adult individual residing at 972 West Old York Road, Carlisle, Pennsylvania 17013. Instrument 3. On or about July 28, 2004, Defendant and Plaintiff entered into an agreement whereby Defendant executed and delivered to Plaintiff a Security Agreement for the payment of the amount due, together with interest on any delinquent payment at 12% per annum and collection fees of l8% (the "Agreement"). (A true and correct copy of the Agreement is attached hereto as Exhibit A.) " Default 5. The Agreement required Defendant to pay the amount due to Plaintiff in installments commencing August, 2004. 6. Defendant has made some, but not all payments. 7. To the date of this Complaint, Defendant has failed to pay the outstanding amounts due to Plaintiff, thereby constituting a default. 8. The debt evidenced by the Agreement has been accelerated by Plaintiff as a result of such default and is now due and owing in its entirety. 9. Under the Agreement, interest accrued and continues to accrue on the unpaid balance from the date of default at the rate of 12% per annum until paid in full. Itemized ComDutation Of Amount Due 10. An itemized computation of the amounts due from Defendant to Plaintiff as of January 27, 2006, under the Agreement is as follows: TOTAL $357,218.5 1 $64,299.24 $421,517.75 Principal and interest Collection Fees of 18% I l. In addition to the foregoing, interest continues to accrue on the unpaid balance of the Agreement at the rate of $117.44 per day (12% per annum) from January 28, 2006. Jude:ment Not Beine: Entered Ae:ainst A Natural Person In Connection With A Consumer Credit Transaction l2. The judgment is not being entered by confession against a natural person in connection with a consumer credit transaction. -2- No Assil:!llment Of The Instrument No Prior Entrv Of .Tudl!ll1ent On The Instrument l3. The Agreement has not been assigned. 14. Judgment has not been entered on the Agreement in any jurisdiction. Instrument Not More Than Twentv Years Old 15. Defendants executed the Agreement less than twenty years ago. Demand For .Tudl!:ment WHEREFORE, as authorized by the warrant contained in the Agreement, Plaintiff demands judgment against Defendant in the amount of $42 1 ,517.75 plus continuing interest on the unpaid balance in the amount of $ 117.44 per day from January 28, 2006 and costs of suit. Respectfully submitted, ria . Downey (P A 59891) in G. Weber (PA 89266) PEPPER HAMILTON LLP 200 One Keystone Plaza North Front and Market Streets Post Office Box 1181 Harrisburg, PA 17108-l l81 (7 J7) 255-1155 (7 1 7) 238-0575 (Fax) h.~ Dated: February lO, 2006 Attorneys for Plaintiff Cleveland Brothers Equipment Co., Inc. -3- VElUFICA TION I hereby state that I am the Assistant Credit Manager tbr Cleveland Brothers Equipment Co., Inc., and am authorized to make this verification on its behalf. I verify that the statements made in the foregoing document are true and correct to th,! best of my knowledge, information and belief. I understand that the statements in the foregoing document lire made subject to the penalties of 18 Pa.C.S. 9 4909 relating to unsworn falsification to aU1:horities. Date: d - rfj~ ~~Q'~A:~~ Wirtel Assistant Credit Manapr Cleveland Brothers Eqllipment Co., Inc. I Cleveland Brothe~ C..4.T /IARRlSllVRG-MAlN OFFICE 5300 pAJCTON ST.. P"ONII 7J'-S6402111 FRACKVlLLE PHNNsn.vANIA R.QUTE'l-I"HONI!: 1I7.l1?+JS60 WHITE DI!Il~: Sf A TE COLLEGE OLDllOun: I5-PHJN&: 111-51a.2SS1 19.:iSSTEWAR.TDRJVIHItON&; 11'1-2.37013)1 WlLKES-BAlUlE 9"10 WlLKES-BAItN!I TWP. BLvD.-mONS: 711-m-8'41 PHIUPSBVIlG 1in A.LDa st.-'flONE: ""'342..4210 MANSFIELD LANCASTER u.S.I01Jn.ti2A~r.,ftONE: '1'-6li2.7171 1l0000~n.tHOM!: 717..:59-4~ SECURITY AGREEMENT Made on July 28, 2004, between Paul Thrush n8A 8&D Excavating 972 West Old York Road, Carlisle, P ^ 17013 (being lh. debtor an<! h....in colle<! "Buycr'), a corporation, partnership or individual. said&d<lr..s being "iluyer's mailing addres' an<! place ofbu,in"". or residence al which tbe property covere<l hereby will be located, ."d Clavellllld Brothe.. l!quipmtnt Co.. be., 5300 Paxton Street, Harrisburg. Pennsylvmia 171 O~ ($CCurod ]>al1Y and h.r.tn called "S.II."), said &d<lr... being Seller', address at which information ,:onceming SeUer's s.curity inmo.t hereunder may b. obtaine<!. Buyel' and S.lIer have entere<! into a cmain sales order contract (hereinafter r.ferred to as ",:be contract") pursuant 10 which Seller has agree<! to ...1Illnd Buyer has agr.ed to purchase certain equipment As s""urity for payment of the total due hereon as set forth below. including but not limite<! to any an<lall cbllf!C5 relate<! th_o. an<! for llnY amount which may become due and owing Seller by Buyar pUISUlllltlO the conlracl for any l1Iason, Ii well as to secure the payment and pcrfonnance by Suyer of any other obligation. which Buyer may havo 10 Seller. .ilber now .xisting or hereafter incurred or accrue<!; Buyer does hereby give Seller a securily interesl in the equipmcn~ machinery. and/or goodi dO$Cribe<! bel.ow, all of which is hereinafter referred to Ii "lh. equipment": DESCRII'TlON Refinance: One Caterpillar 953 Track Loader, SIN 20Z01337 One Caterpillar 416 Backhoe Loader, SIN 5PC04807 F.O.B. Buyer will promptly notify Sell.r and in writing, of any discontinuance of."y place of bus in.... tbe establishmenl of any new place of bus in.... or any change oflocalion of said property. f'RJCIt ."....~.........._..........................._.... $ LESS TRADE ALLOWANCE "......... S BALJ\liCE............................................. S &.ALES TAX ............................................. $ HAlJLING .................................1100'''...." $ OPEN ACCT & REPAIRS ................. S INSURANCE ........"............................. 5 F'ILINGrrERM FEE ............................ $ TOTAL................................................. S CASH WITH ORDER...,............... 5 CASH ON DELIVERy,................ $ RENTAL PAYMENTS ................. S 'SEE SCHEDULE A 315,101.68 0.00 315,102.68 0.00 0.00 3,242.08 0.00 150.00 328,594.76 0.00 0.00 0.00 NET 8ALANCE ........................... $ FINANCE CHAlil.GE ................... $ TOTAL DlJE.......,.......................... S 328,594,76 65,573,75 394,168,51 Which Ml> huyer(s) agIec(s) to pay at: M&T eank in'SEE SCHEDULE A installmenlS of "SEE SCHEDl!LE A eacb, and a fuull installment o,"SEE SCHEDl!LE A said installmetlto commencing AU!l';~t28, 2004 as evidence by promissory DOte(s). Any delinquenl pllyment shall bear inlerestst UOIo ftom tho <late of default. EXHIBIT A Bl.!yCT itrees: at aU timcslD kt:cp lhc equipment inlllrtd in SUQh fCN'tn, in sUlOh fQrm. in :such tomplUlia. in such amounts and sgainst $lich "50 as may be ~ptabl. cUd'!'. wirh provisions .wtsfactory to S~11er fOf payment or 1111Q!liSfls thorcundet to Seller 1$ ill; intuQSt5 may appear, and. j( required, to deposit lhe policies whh Seller: any Sum. ~ived by Seller in pl)'menl of loJSeS under said policies may, at Sellon option. be applied on the ba'-ncc of the amount Qw-cd to Seller by Buytt whether or not the same: ifthcn i Of payable-, pr may be delivered by SellQ' Ie. Buyer for the purpoK ofrepairing or T'CStering the equipment. a~ also atl'lC8: tha.t.11 (:quipmcnL, ~essories and parts now or eaftm' aaached or added to the equipmc:n.1 or I.*d in connmtion &herewith shall at ~ become pin therwr. II'Id Chat loa, injllt'Y or deftruction of laid cquipmtnt mall nor rebse "C:duce BLlye(s obligations 10 Selltl'. pul'$uatlt to the contract. this ^srcmnent. or lI1yptornis50ry T19te5 ext9LIted or deliverlJ~ by Bu~ '0 Seller with resp!ld \C) Itle conlrac:l In lilion, Buyer .area: to k"P the equipmeftt in ... tood condilion u when received. reasona~e WQr only ~c:epkd, and In :~o doinJ and Ii aU other times to keep the tquipmc,,, free I cleat of all liens and enc.LlmbrancCJ, voluntary or involuntary. not to sell. or otherwisQ h'afer any in~SI of Buyer in 11':J. tquipntnt; QOt 10 remove the cqUlpmlfll fonn Ihe 'reJS at which ir is 10 bo )ocate!! U $at forth eXcept for temporary periods in the normal and CUSWMlII'Y use thI;rcofi 10 bnft"<I~iaJely norify Seller in writing of l1\)f seirure (If . levy ;m, loss of possession of. des~ion of, or damage to the equipmen1~ and to perfonn any defauhcd atmml;J1t& of BlIyerj imy .-rJounts tmptndcd in smh performancC, with mtcrcft .reon shall be p.yablc by Buyer ID Sellu Qfl demanct and the seeuri1y interes1 given herein shall further "rva as seelft'ity for the rtimbursemtru thereof to Seller. au.yer will pay all its of filing any financin&. continuation. Of tenninllion sta1Omcr'lts with respect to the Ilecurity interest c:rcatcd by mis Agre:c:nieI'U; Seller is hereby appointed B~s attozmy m fact do "Sel"''' option and At BUFs expcnst:. all "1:$ and thins;$ which $c:ller may deetJ\ neceuary to perfect and contin\lC Fi",f"~ the sel:1.lrlty intet'csll;lJ'tated b)" this ^Bl'eetnent ~ 1Q pro,"' the equipment. Buyer .twll be in default ~und" upon failure 10 pay when dUQ any amoun1 payatlle pursuant to the contm: ur under any promissory note .....hich may have been given SeJJe, w1th JUJ)CCJ. thertto 9J 1.JpOn failure to observe and perfonn any of BU)'l;ts obliptions pursuant to this ^sreemcnt, tlf if proceedinp, in which 9u)'flr i. aJltpd 10 bt insolvent unable 10 pay Buyer's do1ilbi lid they mMlJl'C i. inltinncd by or apinst Buyer \lnder any Dfthe promiot\c of the Bankrqptc~ Act or any other law. or if BlJ)'Qr miIW II1lUriplmc:nr Dr 1 benefit of crec:li1OtS. Whenever 8\.1yet is in defal.llr pu,",uant to the connct atld all Dther sum. f01' whith ctJI\1raQt, itld prmlis:sory notes, or this A&ttmtmt, th, entire unpaid lance OWinl to Seller by Buyer P\lPUllnt to the Cootnlcl and all ather SUms tht which Buyer is liable to SefJiW' PUfI'UIIJ1t 10 Vie conna. said prom;SSl)J'Y 1I'QlI:$, tit thll AJremIm'l.l shaD come immediately dLlt and payable In Seller's OpUQn Wllho"t notice 10 9U)'11'. and Seller may proceed to enforce paymenl ofthc s:ame and to exercise any or 111 cHthe rip atWI llcdies at'tcrddd by raw or <<Itlity~ and IpOdflAlJy but not cxclusivtJr. thou remfldies aftwdtd by the Uniform CommcrcilJ coda as enacted in the CommOl1Wallth offtnnS)1V1ni., d upon demand by '''IlIT. Buyer shallassmnb1e the tQ\.Ilpment anet malt.. it available to Seller at a place reuonabty lXlRvef:i.cnt to 8",~ JRd Seller_ SlJyer hel'tby authorizes the Prothonotary or any a~ey af lItny coun of record, wllC:never 8\1}<< is in defa'llt1 pIlduantlCt the conu.ct land/Qr Did prombsory nolea dlDf thil A~t, to appe.ar for and conieSl judpnen1as often ill n~lIry .insl Bu)'Cr (t> in any action 10 retOV~ posMSSion ortM equipment lW1d (2) (or.II NmS' payable . Buyor purCUlnt tC) the COntrlct, !mcl/or this Agreement and/or said pt'omissOl)' notes, to;cthet with 18~ ~f added IS a ~oRedi(l1\ fee:_ Qu')'tt waives all mon: and appeals. the ~t UI stay of ~uUon, and the benefit of an exemption laws of any IIitatc n<lWat hcrciltct in effect. Delay in the exetc.ist of Sellers rights. whether under the ~orUraCl11 dlis ^&reemcnl Dr said promiisory notes, r::.11 not constitute a waivtt thereof. The WJiver of any :flLllt sMjJ not be-" w.liver of any jtlbsequmt default. BU}ler acknowle4;es dW, no otal.cst:1\tltton', wamnries (If JUa;-attties have been made by Seftcr 10 BU}Ier. Bu\'Of aclcnowled...lIIIl Sellet lias &iven notice: to aUF Iha. Soller may ",Ill" an<ll... nv&OlI.." 10 o!hird p>>1y Sellers 'iglllS (I);n the conlroct, (2) in thi. A_lOt Id (3) in said promissory qat!:l. all for a valuable consideration, To induce said dlird party 10 pay nid vaJ\.lablc COJlsldCf1ltiJrl_ 1'0 induoc uid third. party to pay said Vllu.ble msideTadon therefor, Buyer. intmdina leplly to be bound hereby, aarccs with Slid third part)' IhaI (a) upon such apianm:mt and nogor:iation or o~ I1MJter. ,Ill rights, (J(JWm tnd medil:l of Selltr hcre\Mder and under said promiuoJ'y nata and pursuQtt to the l;Oftbact sIlall belong to and be ~crcilab]c by said third pany includinG but not limited 10 the pow6r ld rip to conf_ judpmmt(l) and, upOn receipt 6t notice of S'uch l55iennmrt or ne'gmiation Of other traAlf~. Bu)'W wHl ~er performllPCC ofBuycr'1 obligadQflS undor the mtnCl, 1&ndIr ltIis ^lJ'Ce"ment, and tinder saki promissory nole.I1O s:1id third pi:rty. rilthcr than 10 Seller. ancI (b) in any action brOU&ht by ,:aid third p.rty apinlt Buyer to recover any ~ms under ilie.ennt1act,.. under thil A&reemonf., Dr I1tldcr said promisAOty nQ1l:K. or to reco'let pos$wion of the: equipment, Bu)'tlr will not idsen JI a defense, COlJflterelaJm:. setoff. WI complaint, or otherwise any cl",itn. known or unknDwn. which DuYtl' now has or hereafter ~uires apinsa Seller, eM)~ that BUF has paid the total "Tnount due- Sener IP'$Uln1 tQ the cont:rac1. The ~f'J1 QlJuse (b) shall not apply if said equipmen1 is "consumer goods" as defined in the tJnifOl'm CQrnmetc:.ial Code of Pennsylvania. Despite any JOh usi_onl, Sollet shon "",0;. liabl" \<l Buyer for the performance .e oll.fSvU.... .bllp".... t.lluy<:<, includi1ljlh;;", illising hvt<undtr. )aul Thrush DBA B&D Excavating (seal) 3Y~z[~ ~ ame)" (title) By ~..-/ ~ "{name) (title) BY~./ (name) (title) CLEVELAND BROTHERS EQUIPMENT CO., INC. ey L. Grimes, Assistant Secretary PAULTHRUSB DBA B&D EXCAVATING SCHEDULE A Payments 1-5 Payments 6-8 Payments 9-17 Payments 18-20 Payments 21-29 Payment 30 $ 7.,500.00 $ 0.00 $ :~,OOO.OO $ 0.00 $ 4,000.00 $3 '18,668.51 CLEVELAND BROTHERS EQUIPMENT CO., INC., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA Plaintiff vs. NO. D&. S):2. ~( I.~..-- PAUL D. THRUSH, dlb/a B & D EXCAVATING CIVIL ACTION Defendant CONFESSION OF JUDGMENT Notice Under Rule 2958.1 Of .Tudement And Execution Thereon Notice of Defendants , Rights A judgment in the amount of $421,517.75, plus continuing interest on the unpaid balance in the amount of $117.44 per day from January 28, 2006, and costs of suit, has been entered against you and in favor of the Plaintiff without any prior notice or hearing based on a confession of judgment contained in a written agreement or other paper allegedly signed by you. The Sheriff may take your money or other property to pay the judgment at any time after thirty (30) days after the date on which this notice is served on you. You may have legal rights to defeat the judgment or to prevent your money or property from being taken. YOU MUST FILE A PETITION SEEKING RELIEF FROM THE JUDGMENT AND PRESENT IT TO A JUDGE WITHIN THIRTY (30) DAYS AFTER THE DATE ON WHICH THIS NOTICE IS SERVED ON YOU OR YOU MAY LOSE YOUR RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, P A (717) 249-3166 ~W~~9891) Justin G. Weber (PA 89266) PEPPER HAMILTON LLP 200 One Keystone Plaza North Front and Market Streets Post Office Box ] 18 I Harrisburg, Pennsylvania 17 108-1181 Attomeys for Plaintiff Cleveland Brothers Equipment Co., Inc. CLEVELAND BROTHERS EQUIPMENT CO., INC., Plaintiff vs. PAUL D. THRUSH, d/b/a B &DEXCAVATING Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01." - )?;:; 2. C~ .~~ CIVIL ACTION CONFESSION OF JUDGMENT CERTIFICATE OF RESIDENCE I hereby certify that the last known addresses of the plaintiff and defendant are as follows: Plaintiff Cleveland Brothers Equipment Co., Inc. 5300 Paxton Street Post Office Box 2535 Harrisburg, PA 17105 Dated: February 10, 2006 Defendant Paul D. Thrush B & D Excavating 972 West Old York Road Carlisle, PA 170[3 ~~~ B la . Downey CPA 5989l) Justin G. Weber CPA 89266) PEPPER HAMILTON LLP 200 One Keystone Plaza North Front and Market Streets Post Office Box 1181 Harrisburg, P A 17108-118 1 (717) 255-1155 Attorneys for Plaintiff Cleveland Brothers Equipment Co., Inc. ( '-.J I'>~' ~ ~ I ~, G ~ F\ f'S' rT; :::! f " ~ 8) \:..~ -'1 ~ J.1 G,;, \ ~ --.l , -.t ' CJ ~) " '" "'" ~ "-' {" -," "'" r ~ - (-c~ ~ I',; ,. 'f:J ., ("1 r' U) i-..J ..... <:> , '" (' . ~ CLEVELAND BROTHERS EQUIPMENT CO., INC., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO. 06-832 CIVIL TERM PAUL D. THRUSH, d/b/a B &DEXCAVATING CNIL ACTION Defendant CONFESSION OF JUDGMENT AFFIDAVIT OF SERVICE PURSUANT TO PA. R.c.P. 405 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN THE UNDERSIGNED, Justin G. Weber, being duly sworn according to law, does depose and say as follows: I. I am a competent adult and an attorney duly admitted to the Bar of the Supreme Court of the Commonwealth of Pennsylvania, having Attorney Identification Number 89266. 2. On February lO, 2006, I caused the Complaint in Confession of Judgment and accompanying Confession of Judgment, Notice of Entry of Judgment, Certificate of Residence, and Notice under Rule 2958.1 to be served upon the defendant by the mailing of a true and correct copy to the defendant by United States certified mail, return receipt requested, postage prepaid, addressed as follows: Paul D. Thrush, B&D Excavating, 970 West Old York Road, Carlisle, PA 17013 ("Service Address"). " 3. I received the return receipt, which was postmarked on February 12,2006, indicating that the documents were delivered to and accepted at the Service Address on behalf of the defendant, thereby completing service pursuant to Pa. R.c.P. 403. The return receipt card is attached hereto as Exhibit "A". . !1 LL- Brian . Downey (PA 59891) stm G. Weber (PA 89266) PEPPER HAMILTON LLP 200 One Keystone Plaza North Front and Market Streets Post Office Box J l8 J Harrisburg, PA 17108-l 18l (717) 255-1155 Date: February 15,2006 Attorneys for Plaintiff Cleveland Brothers Equipment Co., Inc. SWORN TO AND SUBSCRIBED BEFORE ME THIS ,,(~DAY OF Fe, bruary, 2006,' tu. _ I=t;;~ . utziilR Notary Publici y ommlsiWillih res: Malianne Settle, Notal'f Public City Of Harrisburg, Dauphin County My Commission Expires June 24, 2006 MAmber Ppnnsvlvf3fli8 A.",sociation Of Notaries SENDER. COMPLETE THIS SECTION . Complete items 1, 2, and 3: Also complete item 4 if Restricted Delivery is desired. .. Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: PMv( b ,"'....IA. Sy, t)' ~\) ~'i-.c.&l.VCl.-\-;n~ 1-\lO \N ~<;..\- 0\ ol. , 'i Ov \Z. \<-M. (f/\vf,C,k 'PD 11(,'1,) \ 2. Article Number (Transfer from service label) PS Form 3811, August 2001 . . A. SignatlJ1e x ,~ B. Ai'Ceived by ( Primed Nam . / .. I o-.k. o Agent o Addressee G\D4ef~ D. Is delil/ery address different from item 11 0 Yes If YES, enter delivery address below: 0 No I Domest'lc Return Receipt 3. Service Type IXlCertified Mail o Registered o Insured Mail o Express Mail "r' ~~~.:.' o C,O,D, '. 4. Restricted Delivery? (Extra Fee) DYes 7002 2410 0001 2369 6290 102S9S.02.M-154C EXHIBIT A r:; -) --. '., ;;\ ---:-.1 ......" ;;, ,~ " ..-----------